BRCGS has issued position statement P708 for the Global Standard Packaging Materials Issue 7. It is mandatory for every audit conducted on or after 10 August 2026, it changes two clauses, and it aligns the Standard with the GFSI Benchmarking Requirements 2024. If your site is certificated to Issue 7, or is working towards it, these two changes are now part of what you will be audited against.
In short
- P708 is a BRCGS position statement for Packaging Materials Issue 7, effective 10 August 2026. Position statements are mandatory from their stated implementation date.
- It changes two clauses: 4.4.1 (site security and product defence) and 4.8.2 (housekeeping and cleaning).
- Clause 4.4.1 now requires that personnel who carry out the threat assessment and develop the product defence plan have received appropriate training, cross-referenced to clause 6.1.
- Clause 4.8.2 now requires cleaning procedures to consider disinfection where appropriate, and to include validation as well as verification, based on the risks of the intended use of the product.
- The purpose is alignment with the GFSI Benchmarking Requirements 2024.
- Neither change is large on paper. Both reach into requirements that are already fundamental, which is why they are worth acting on now rather than the week before an audit.
What a position statement is, and why it is not optional
BRCGS publishes position statements to clarify or amend a Standard between issues, without reissuing the whole document. They are mandatory in their use from the date specified for implementation. In other words, from 10 August 2026 an auditor assessing a packaging site against Issue 7 assesses it against Issue 7 as amended by P708, whether or not the site has noticed.
That is the trap. The printed Standard on your shelf still says what it said in October 2024. Nothing in the book changes. The requirement changes anyway.
Change one: clause 4.4.1, training for the threat assessment team
Clause 4.4 covers site security and product defence. Clause 4.4.1 already required a documented threat assessment of the security arrangements and the potential risks to products from any deliberate attempt to inflict contamination or damage, covering both internal and external threats.
P708 adds a requirement about who does it. The personnel conducting the threat assessment and developing the product defence plan must have received appropriate training, and the clause cross-references training and competence at clause 6.1.
Why this is more work than it looks
Clause 6.1 is a fundamental requirement, and it does not stop at delivering training. Where personnel are engaged in activities relating to process control points and critical control measures, 6.1.3 requires competency assessment, not attendance. Training records under 6.1.5 must carry the trainee name and confirmation of attendance, the date and the duration. A threat assessment signed by a manager with no recorded training in threat assessment now has a clause number attached to it.
What to do about 4.4.1
| Step | What it means in practice |
|---|---|
| Name the people | Write down who carries out the threat assessment and who develops the product defence plan. In most sites this is two or three people, and at least one is usually from outside the technical function. |
| Define the competence | What must they be able to do? Identify internal and external threats, assess vulnerability of intake and storage points, evaluate access control, and review the assessment when circumstances change. |
| Deliver and record the training | Formal course, in-house session or structured coaching. The route matters less than the record: name, attendance, date, duration, content, trainer. |
| Assess competence | A short documented assessment, or a supervised first assessment reviewed by someone competent. Attendance alone is thin evidence. |
| Add it to the training matrix | With a refresher interval and a trigger to retrain when the threat assessment method or the site changes. |
Change two: clause 4.8.2, disinfection and validation
Clause 4.8 is housekeeping and cleaning, and it is one of the nine fundamental requirements in Issue 7. Clause 4.8.2 already required cleaning procedures for buildings, equipment and vehicles, with schedules stating responsibility, frequency, method, chemicals, equipment, the standard to be achieved and how that standard is verified.
P708 revises it in two ways.
- Disinfection, where appropriate. The procedures must consider disinfection and not cleaning alone. Whether disinfection is needed at your site is a risk-based decision, but it is now a decision you have to make and record rather than one you can pass over.
- Validation as well as verification, based on the risks of the intended use of the product. Verification asks whether the standard was achieved on the day. Validation asks a harder question: is the method you specified actually capable of achieving that standard at all?
The word that does the work is validation
Most packaging sites can show cleaning records and a supervisor signature. Far fewer can show evidence that the specified method, at the specified concentration and contact time, achieves the specified standard. That evidence is validation, and it is what P708 now asks for. If you already validated your cleaning programme as a prerequisite under clause 2.5.4, you are most of the way there and should cross-reference the two. If you did not, this is the gap.
What to do about 4.8.2
| Step | What it means in practice |
|---|---|
| Decide on disinfection | Assess, on the basis of risk and the intended use of your product, whether disinfection is required anywhere: water-based inks and coatings, wet cleaning, condensation, or product in direct contact with ready-to-eat food all push towards yes. Record the decision either way. |
| State the standard | Define what clean means for each item and area, with photographs where the judgement is visual. This was already required and is still the most commonly missing element. |
| Validate the method | Show that the method, chemical, concentration, contact time and temperature you specified achieves that standard. Swab or residue results across a series of changeovers, supplier data on contact time, or a documented trial all count. |
| Keep verifying | Verification continues as before: someone other than the cleaner checks against the defined standard and records it. |
| Link it to 2.5.4 | Where cleaning controls a specific hazard identified in your HARA, the adequacy of that programme for that specific hazard must be validated anyway. Do it once, reference it twice. |
Who this affects, and by when
| Your situation | What P708 means for you |
|---|---|
| Certificated to Issue 7, audit due after 10 August 2026 | Both changes apply at your next audit. Close them now; the 4.8.2 validation evidence in particular is not something to assemble in the final fortnight. |
| Currently implementing Issue 7 for a first certification | Build both in from the start. Neither adds much work if it is designed in; both are awkward to retrofit. |
| Still on Issue 6 | Issue 7 was published on 28 October 2024 and became effective for audits from 28 April 2025, so Issue 6 is behind you. Plan the transition and build P708 into it rather than closing the same clauses twice. |
| On the unannounced audit programme | Your audit can fall anywhere in the last four months of the cycle. Treat 10 August 2026 as the date these controls must already be working, not the date you start. |
Train your team on the whole Standard
ASC’s Implementation of BRCGS for Packaging Materials Issue 7 course works clause by clause through all seven sections, including site security and product defence (4.4) and housekeeping and cleaning (4.8), with the P708 changes built in. It covers all nine fundamental requirements, carries a downloadable implementation toolkit with every Issue 7 sub-clause pre-loaded into a gap analysis, and ends with a graded final assessment and a QR-verified certificate.
See the implementation courseStart with the introduction course
The order to do this in
- Download P708 from BRCGS and read it against your own copy of the Standard. It is short.
- Name the people who do your threat assessment, and check what training record exists for them. This is usually a one-hour job that reveals a gap.
- Pull your cleaning schedules and look for two things: a defined standard, and evidence that the method was validated. Most sites find the first and not the second.
- Make and record the disinfection decision for each area, on the basis of risk and intended use.
- Raise anything outstanding in your corrective action system under clause 3.13, with a root cause and a dated plan, rather than leaving it undocumented. An auditor who finds a known gap being actively managed sees a working system.
Common questions
What is BRCGS position statement P708?
P708 is a position statement issued by BRCGS for the Global Standard Packaging Materials Issue 7. It amends clauses 4.4.1 and 4.8.2 and is effective for audits conducted on or after 10 August 2026. Position statements are mandatory from the date specified for implementation.
Which clauses does P708 change?
Two. Clause 4.4.1 on site security and product defence, which now requires appropriate training for the personnel who conduct the threat assessment and develop the product defence plan, cross-referenced to clause 6.1. And clause 4.8.2 on housekeeping and cleaning, which now requires cleaning procedures to consider disinfection where appropriate and to include validation as well as verification, based on the risks of the intended use of the product.
Why did BRCGS issue P708?
To align the Packaging Materials Standard Issue 7 with the GFSI Benchmarking Requirements 2024. BRCGS standards are benchmarked against GFSI requirements, and alignment is what allows the certificate to be recognised by retailers and brand owners that specify GFSI-recognised certification.
Do I need to reprint or rebuy the Standard?
No. The Standard itself is unchanged; the position statement sits alongside it. You do need a genuine, original copy of the current Standard under clause 1.1.7, and you need to be aware of changes to the Standard or the protocol published by BRCGS, which is exactly what a position statement is. Keep a record of having checked.
Does P708 mean every packaging site now needs disinfection?
No. It means every site must consider disinfection where appropriate and record the decision. A dry converting operation with solvent-based inks may reasonably conclude that disinfection is not required in most areas, but that conclusion has to be the documented output of a risk assessment that takes the intended use of the finished product into account.
When did BRCGS Packaging Materials Issue 7 come into force?
Issue 7 was published on 28 October 2024 and became effective for audits from 28 April 2025, replacing Issue 6. P708 then amends Issue 7 for audits from 10 August 2026.
Is housekeeping and cleaning a fundamental requirement?
Yes. Clause 4.8 is one of the nine fundamental requirements in Issue 7, alongside 1.1, 2.0, 3.4, 3.5, 3.10, 3.13, 5.4 and 6.1. A lack of focus on a fundamental requirement may result in certification not being granted, which is why the 4.8.2 change is the more significant of the two.
Where can I get training on Issue 7 in South Africa?
ASC Food Safety Training offers two self-paced online courses for packaging sites: an Introduction to BRCGS for Packaging Materials Issue 7 covering the Standard and the audit protocol, and an Implementation of BRCGS for Packaging Materials Issue 7 course that works clause by clause through building the system. Both can be taken as a two-course bundle. ASC is SAATCA registered and FoodBev SETA accredited, and every certificate carries a QR code that resolves to a verification record.
This article summarises a publicly published BRCGS position statement for information. It is not a substitute for the Standard: a site is audited against the Global Standard Packaging Materials (Issue 7) and the position statements in force, and both the site and the auditor need an official copy. Confirm the current position statements on the BRCGS website before you act.